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After SR 26-2, Agentic AI Governance Has to Be Load-Bearing

Regulators took agentic AI out of the model-risk rulebook and left the duty to govern it in place. The standard a bank writes to fill that gap is worth exactly what its architecture can enforce — and…

DD
David deBoisblanc  ·  Co-founder & Principal
8 min read · Financial Services & KYC/AML
Latest Insight For Executives 8 min read
Financial Services & KYC/AML
Senior-level depth
The CCO and CFO Inherit SR 26-2
The guidance that pulled agentic AI out of model risk didn't say who inside the bank now owns the cost of governing it, and that silence is where the exposure collects. SR 26-2 carved generative and agentic AI out of model risk and declined to speci…
SR 26-2 Carved Out Agentic AI. The Liability Didn't Move.
In April, the framework that has governed bank model risk for fifteen years was rewritten, and the fastest-moving AI in the institution was deliberately left outside it. SR 26-2 rewrote bank model-risk guidance in April and deliberately placed gener…
Financial Services & KYC/AML For Executives
The CFO Question on Agent Governance Spend
Capital requests for AI agent governance are arriving on CFO desks one platform at a time, each defensible in isolation, and the gap between them is where the financial exposure lives. The reason these requests are arriving now is that the market ju…
Your Agents Can Read the PDF. They Cannot Defend It.
Before any agent can act on a financial record, something or someone has to turn that record into trustworthy structured data. That handoff is where many institutions are quietly failing today. The pattern is familiar to anyone who has worked inside…
Financial Services & KYC/AML For Executives
Semantic Coherence Is the KYC Control Examiners Will Ask About Next
Your next agentic AI deployment is likely to struggle under examination for reasons your model risk framework wasn't built to catch. Industry analysts including Gartner and McKinsey continue to report that the majority of enterprise AI projects fail…
Rethinking LLMOps for Fraud and AML: Building a Compliance-Grade LLM Serving Stack
A new paper on LLMOps for fraud and anti-money-laundering workloads reframes compliance inference as a serving problem. Prompts are prefix-heavy. Outputs are short and schema-constrained. Most production stacks are tuned for the wrong workload — gen…
Financial Services & KYC/AML For Executives
When Process Breaks Down, Fraud Finds a Way: Through Invoices, Expenses or Both!
A subsidiary lost a material share of its annual turnover for eight straight years to a fraud scheme that never tripped a single control, because the controls were watching the wrong things. The Fintech Times this month walked through the mechanics…
Financial Services & KYC/AML
Rethinking LLMOps for Fraud and AML: Building a Compliance-Grade LLM Serving Stack
A new paper on LLMOps for fraud and anti-money-laundering workloads reframes compliance inference as a serving problem. Prompts are prefix-heavy. Outputs are short and schema-constrained. Most production stacks are tuned for the wrong workload — gen…
Financial Services & KYC/AML For Executives
Your AI Governance Chart Has One Name on It in Court
Courts are starting to signal what risk officers already suspect: when an AI system causes harm, the bank that deployed it owns the liability, not the vendor that built it. A recent CIO feature on AI accountability lays out a dynamic that should lan…
Financial Services & KYC/AML For Executives
The Hidden Capex in Treasury's Stablecoin Rule
Treasury's stablecoin rule turns a compliance question into a capital question, and the meter is already running. What CFOs and compliance leaders need to know: The clock is twelve months from rule finalization, with comments closing June 9 — short…
Financial Services & KYC/AML
The GENIUS Act Just Became an Architecture Problem
Treasury's proposed AML and sanctions rule for stablecoin issuers reads like a compliance document. Read it again as an architect, and it's a system design specification — one that quietly moves the hardest decisions from the legal team to the platf…
Financial Services & KYC/AML
Why Knowledge Graphs Are Becoming the Center of Gravity in AML Architecture
The leading institutions know this. Major banks have graph initiatives, entity resolution programs, and ML-based transaction monitoring in production or advanced pilot. The question at the top of the market isn't whether to move beyond rules — it's…